In the interest of upholding its esteemed business reputation, Evrofinance Mosnarbank (the Bank) hereby affirms its steadfast commitment to, and support for, the international community's endeavors to combat the money laundering, the financing of terrorism, and other illicit activities.

COMBATING LEGALIZATION

There are rulings and legal acts in the Russian Federation with respect to counteracting legalization (laundering) of proceeds from crime in order to implement the standards of the International Financial Action Task Force (FATF, www.fatf-gafi.org). The Federal Service for Financial Monitoring (Rosfinmonitoring) is a member of the Eurasian FATF and follows its standards on bank supervision, principles and guidelines to apply the best practice.

The Bank follows the high standards on counteracting money laundering (legalization of illegally acquired proceeds) and applies all measures properly in accordance with Federal law No. 115-FZ dated 07.08.2001, “On Counteracting Money Laundering (Legalization of Illegally Acquired Proceeds) and Combating the Financing of Terrorism”. (Federal Law on Counteracting Money Laundering (Legalization of Illegally Acquired Proceeds)

The Bank measures with respect to counteracting money laundering (legalization of illegally acquired proceeds) and financing of terrorism aim to guarantee the rights and legal interest of the clients and the state, as well as to prevent the involvement of the Bank in punishable actions.

The Bank has developed and applied the Internal Control Rules for Combating the Legalization (Laundering) of Income Derived from Criminal Activities and the Financing of Terrorism and Weapons of Mass Destruction Proliferation (hereinafter, the Rules) in accordance with the requirements of the Russian legislation and the guidelines of FATF, Basel Committee on Banking Supervision and Wolfsberg Principles, and all internal control instructions are fully implemented in the above Rules.

The Rules aim to maintain the effectiveness of the internal control system on combating the legalization (laundering) of income derived from criminal activities and preventing the financing of terrorism and weapons of mass destruction proliferation (hereinafter, AML/TF and WMDP) at the acceptable level to manage the risks of legalization (laundering) the income derived from criminal activities and the financing of terrorism and weapons of mass destruction proliferation, as well as to prevent the Bank management and its employees involvement in the legalization (laundering) income derived from criminal activities and in the financing of terrorism.

All employees of the Bank, who are engaged in (or facilitate) banking operations and other transactions, regardless of their official position, are involved within the scope of their competence in the execution of the Rules. They are required to exercise appropriate vigilance concerning any unusual operations and transactions, with particular emphasis on factors that influence the evaluation of client risk and on dealings with clients presenting an elevated risk profile.

The Bank implements measures designed to uphold and enhance the internal control system for AML/CFT and FPWMD, and also carries out an annual audit to assess the organization of the AML/CFT and FPWMD processes.

The Bank is supervised by the Central Bank of the Russian Federation (Bank of Russia, www.cbr.ru) and Rosfinmonitoring(www.fedsfm.ru).

Client Verification Procedures

In accordance with the “Know your Client” principle, the Bank provides an in-depth analysis and verification of clients, considers their representatives, beneficial owners and beneficiaries, monitors client cash flows on bank accounts (deposits) in order to meet the requirements of the Russian legislation, including those related to AML/TF and WMDP.

The Bank also requests additional information from customers (if necessary) in order to clarify the nature of transactions, activities and business features.

In order to implement the identification program, as well as guided by Article 7 of the Federal Law on Combating Money Laundering, the Bank is obliged to update the information:

- regarding clients who have been categorized into the low risk group for the occurrence of suspicious transactions in alignment with the Bank's internal control rules, as well as their representatives, beneficiaries, and beneficial owners, a review shall be conducted not less than once every three years. Should there arise any doubts concerning the veracity and accuracy of information previously obtained, such a review must be undertaken within seven business days following the emergence of such doubts.;

- regarding clients who have not been categorized into the low risk group for the occurrence of suspicious transactions in alignment with the Bank's internal control rules, as well as their representatives, beneficiaries, and beneficial owners, a review shall be conducted not less than once every year. Should there arise any doubts concerning the veracity and accuracy of information previously obtained, such a review must be undertaken within seven business days following the emergence of these doubts.;

 Under 14 art.7 of Federal Law No. 115-FZ “On Counteracting Money Laundering (Legalization of Illegally Acquired Proceeds) and Combating the Financing of Terrorism” all clients are obliged to provide information, requested by the Bank to meet the requirements of the above Federal Law, including information on their Beneficiaries, founders (participants) and Beneficial owners.

All the documents and information provided to the Bank, on which the Bank performs identification tests of the client, its representative, beneficial owner and beneficiary should be effective at the date of provision (receipt).

Client Representative

Client representative is a person acting on behalf of and in the interests or at the expense of the Client, whose powers are based on a power of attorney, contract, act of an authorized state or local government body, law, as well as the sole executive body of a legal entity.

Beneficial owner

Beneficial owner is an individual that either directly or indirectly (via third parties) owns (has over 25% interest) a corporate client or may control the client’s actions, including influence the decisions taken by the client. The Beneficiary owner of an individual client is that individual, unless there are reasons to believe that another individual is the beneficiary owner.

According to Art. 6.1 of Federal Law “On Counteracting Money Laundering (Legalization of Illegally Acquired Proceeds) and Combating the Financing of Terrorism”, legal entities are obliged to have information on their beneficial owners and to take reasonable and available actions to identify their beneficial owners.

A legal entity is obliged to update information on its Beneficial owners at least once a year and record the provided information.

Beneficiary

Beneficiary is a person that is not a direct participant to a transaction, for which benefit the Client is acting.

Beneficiary is:

• in payment for the third party: the third party indicated in the payment details or additional references (for which the payment is made)
• under a bank deposit agreement: the third party in favor of which the deposit is opened
• under a mandate agreement: the Mandator
• under a commission agreement: the Consigner
• under an agency agreement: the Principal
• under a trust agreement: the person for the benefit of which the agreement is concluded
• under insurance agreement: the person for the benefit of which the agreement is concluded

Training and skills improvement

The Bank systematically undertakes training and conducts assessments of the knowledge of employees engaged in the execution of the Rules and the Federal Law on Combating Money Laundering. The trainings are aimed to provide the required knowledge to the Bank employees with respect to AML/TF and WMDP to meet and fulfil the Russian legislation on AML/TF and WMDP.

RECOMMENDATIONS TO CORPORATE CLIENTS

The Bank is obliged to have information about businesses of its clients/potential clients according to the Russian legislation. All questions of the Bank to the client imply a professional attitude to maintain its goodwill and the goodwill of every client of the Bank.

Please note that it is important to preserve your goodwill and not to take any part in dubious financial schemes that may be aimed at the legalization (money-laundering) of the income derived from criminal activities and the financing of terrorism or other punishable actions.

Important!

Please provide to the Bank all information and documents that are requested by the Bank in time, including transactions that your company makes on bank accounts. Please provide to the Bank information and documents on the updates of your identification data.

Please note that in accordance with the requirements of the Russian legislation, a legal entity or a private entrepreneur is obliged to update information in the Unified State Register of Legal Entities and Individual Entrepreneurs (EGRUL), including its seat and types of business in the Russian National Classifier of Types of Economic Activity (OKVED).

Moreover, according to Art.54 of the Civil Code of Russia, the seat is the place of its state registration in Russia. Generally, a legal entity shall be registered at the location of the permanently operating body and, in the absence of such body, any other body or person authorized to act on behalf of the legal entity under a law or another legal act or a foundation document.

A legal entity takes risks with respect to nonreceipt of any legal communications delivered at the address provided in EGRUL and the risk of absence of its representative or body at the above address.

Communications delivered at the address provided in EGRUL are considered to be received by such legal entity, even if its location is different from the above address.

Should a foreign legal entity maintain a representative within the territory of the Russian Federation, any correspondence directed to the address of said representative is deemed to have been received by the foreign legal entity.

Non-compliance with the Russian Federation legislation on the state registration of legal entities and private entrepreneurs incur, without limitation, administrative liability.

Payment Rules

The field “purpose of payment” shall be filled in with all information on the name of goods/services, number and date of the agreement/account. This will enable the Bank to understand the business substance of the transaction and probably help you avoid receiving requests.

Please ensure that your transactions are in line with the types of economic activities indicated in the foundation documents (OKVED).

Check your counterparties at on the official website www.nalog.gov.ru in the "Transparent Business" service. Any business with a legal entity having evidence of a “shell company” may harm your goodwill.

Illicit activities within the financial market.

On the official website of the Bank of Russia, within the information and telecommunication network 'Internet,' there is posted information about organizations engaged in activities that exhibit characteristics of illegality in the financial market. This includes financial pyramids, unauthorized lenders, unauthorized professional participants in the securities market, illicit operations in the insurance sector, and other entities offering financial services without holding a license from the Bank of Russia or being listed in the registry maintained by the Bank of Russia: https://www.cbr.ru/inside/warning-list/ and https://cbr.ru/inside/k_illegals/.

In order to curb illegal financial activities, the Bank of Russia implements actions to block the websites of these entities, and engages in collaboration with law enforcement agencies, other authorized institutions, and foreign regulatory authorities to enact additional measures.

It is important to be aware that current legislation does not allow for compensation to individuals affected by the operations of illicit market participants. Furthermore, it does not authorize the Bank of Russia to directly interfere in the civil legal relationships between entities unlawfully offering financial services and their clientele.

In response, credit institutions, upon detecting among their clientele individuals or entities exhibiting signs of illicit activity within the financial market, as well as clients acting as intermediaries for such individuals or entities (that is, engaging with third parties on behalf of those exhibiting signs of illicit market activity) or counterparts of such entities, are entitled to refuse transaction execution based on paragraph 11 of Article 7 of Federal Law No. 115-FZ. Furthermore, they may assert the rights concerning the client's transactions as provided under paragraph 5.2 of Article 7 of Federal Law No. 115-FZ.

To mitigate the risk of financial loss during transactions with entities identified as engaging in illicit activities within the financial market, we advise you to make regular use of the 'List of Companies Identified with Signs of Illegal Activities in the Financial Market'.

Exercise caution and avoid being deceived by entities operating illegally. Always verify that an organization possesses the required documents and licenses by using https://cbr.ru/finorg/.

Ensure you only utilize the official websites of financial organizations. Websites of legitimate companies are identified by Russian internet search engines with a distinctive symbol (a blue circle with a check mark). A legitimate market participant's website must display all essential information regarding the company, including its licenses and the services it offers.

Exercise caution when selecting contractors and intermediaries, safeguarding your financial assets and business reputation!

CLIENT VINDICATION

Dear Clients,

If the Bank makes a decision to abort transaction instructions or to refuse to enter into a bank account (deposit) agreement in accordance with Federal Law, “On Counteracting Money Laundering (Legalization of Illegally Acquired Proceeds)” the Client is entitled to provide to the Bank documents and (or) information on the date and absence of grounds for the decision to abort the transaction instruction or to refuse to enter into a bank account (deposit) agreement taking into account the information on the reasons of such decision provided by the Bank.

The Bank considers the documents and/or information provided by the Client within seven working days upon their provision and informs the Client on elimination of the grounds for a decision made to abort transaction instructions or to enter into a bank account (deposit) agreement or on the impossibility to eliminate of such grounds based on the documents and/or information submitted by the Client.